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V0311-25 ·17 March 2025 ·consulta-vinculante Medium impact
Tax

Full spin-off of a company lacks fiscal neutrality if segregated assets do not constitute business branches

A company enquired whether it could carry out a full spin-off by dividing its assets into two blocks (a rented premises and a warehouse) to establish two independent companies. The DGT responds that, if the operation is disproportionate, the assets must constitute business branches to apply the fiscal neutrality regime.

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2025-03-17PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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